Proposed deferral of DAC 6 implementation

Proposed deferral of DAC 6 implementation

The European Commission has proposed a three month delay to the initial reporting deadlines under the EU mandatory disclosure rules (DAC 6).

Janette Wilkinson


KPMG in the UK


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On Friday 8 May 2020 the European Commission published a press release confirming that it proposes to defer the initial reporting deadlines under the EU mandatory disclosure rules (DAC 6) by three months in response to COVID-19. Under this proposal the beginning of the application of DAC 6 will remain 1 July 2020.

The proposal is as follows:

  • Reportable arrangements where the first step was implemented between 25 June 2018 and 30 June 2020 would be reportable by 30 November 2020 (rather than 31 August 2020);
  • Arrangements where the reporting requirement is triggered between 1 July 2020 and 30 September 2020 would need to be reported by 31 October 2020; and
  • The 30 day reporting requirement would start on 1 October 2020 (rather than 1 July 2020).

The proposal also includes a power for the European Commission to defer the deadline by an additional three months. However, this may only be exercised if during the existing deferral period ”the exceptional circumstances of severe risks for public health caused by the COVID-19 pandemic persist and Member States have to implement lockdown measures”.

It is important to note the following caveats:

  • This is only a proposal, and approval will be required from the Economic and Financial Affairs Council (Ecofin) and the European Parliament before it can take effect. There have already been suggestions that some Member States are requesting a six month extension rather than the three months proposed;
  • DAC 6 has already been implemented into UK domestic legislation and therefore approval by Ecofin and the European Parliament will not automatically change the current UK implementation dates. The deadlines will only change if the UK Government positively chooses to implement the deferral; and
  • Strictly speaking the wording of the proposal allows for a delay of ‘up to’ three months. There is therefore discretion for member states to allow a shorter deferral period than three months.

In addition, the deferral would have no impact on which arrangements need to be reported; it would only change when the reports need to be made. As a result, we strongly recommend that you continue to prepare your business for DAC 6.

For further information please contact:

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